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Back to the future: attribution of futures contract gains under Australia's CFC regime

Published on 01 Apr 06 by "THE TAX SPECIALIST" JOURNAL ARTICLE

Australia’s Controlled Foreign Company (“CFC”) rules have been the subject of several major reforms in recent years. The reforms have changed the scope of these rules, however, the CFC rules continue to be a significant risk area for taxpayers engaging in international transactions. This paper will focus on one particular type of transaction, namely the potential attribution under the CFC rules of gains made in respect of forward and futures contracts.

Author profile

Dr Philip Bender ATI
Philip is a barrister at the Victorian Bar practising in federal and state taxation and superannuation. He acts for both taxpayers and revenue authorities and has appeared in a number of leading cases in these fields. Philip is also the author of Bender’s Australian Stamp Duties, a book published by The Tax Institute dealing with stamp duty in all Australian jurisdictions. - Current at 26 June 2019
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